Comment Analysis · Docket FS-2025-0001

FS-2025-0001-536081

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS contains internal contradictions regarding wildfire ignition rates on roaded versus unroaded lands (Table 21), lacks quantitative projections for sediment delivery to downstream municipal intakes despite acknowledging high erosion potential from timber activities, and fails to address the legal deficiencies of the prior state-by-state replacement strategy identified by the Ninth Circuit.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
EA analysisEngages the agency's environmental analysis directly.
Analytical gapIdentifies something the analysis fails to address.
EvidenceBacks claims with specific facts, data, or research.
RequestMakes a specific, actionable request of the agency.
AlternativeProposes a different course of action.
LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

Still open to the agency

Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Topics

Wildlife Habitat
- “watched river otters, black bears, moose, and bald eagles in country that holds its wildness”
- “increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality”
- “moose are drawn to road corridors for road salt, which increases human-moose interactions and conflict”
- “verified species include grizzly bear, elk, wolverine, and bighorn sheep”
Water Quality Quantity
- “skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion”
- “can contribute up to 90 percent of the sediment generated by timber sale activity”
- “quantify projected sediment delivery to the more than 7,000 municipal intakes downstream”
- “I work on a river. I understand that what enters the watershed above me arrives below me”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
- “reports far higher fire density on roaded land than inside the affected roadless areas”
Legal Regulatory Framework
- “The Ninth Circuit found the prior attempt to substitute local discretion for the national rule legally deficient”
- “confront its own prior finding that incremental local decision-making erodes nationally significant roadless values over time”
- “rejected the rule's 'inflexible one-size-fits-all' nationwide rulemaking approach”
- “ask the agency to answer the specific questions this record demands”

What it names

National Forests: Gallatin National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

I am a professional whitewater guide on the Gallatin River. For six years I have worked in the whitewater world and spent many of the best days of my life far from a road on wild and scenic rivers. But my home is the Gallatin, the river I love so dear. One side of the Gallatin eventually opens into the Custer Gallatin National Forest. It is on that forested bank that I have watched river otters, black bears, moose, and bald eagles in country that holds its wildness precisely because roads have not carved it open. To contradict it, my commercial crew and I have stared in awe at a fawn, watched it struggle up a rocky river bank with great tenacity, and then procceded to watch it become roadkill seconds later along the other side. Highway 191. I know what roads bring. I have seen the garbage, the road kill, and how easily our wild places can become defiled. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to answer the specific questions this record demands. The wildfire justification offered for this rescission cannot be reconciled with the agency's own findings. The Custer Gallatin's roadless inventory units form the northeastern wall of the Greater Yellowstone Ecosystem, and the forests I guide through sit inside that perimeter. This past summer was one of the worst fire seasons I have experienced. It started with one guide becoming violently ill with a terrible cough, and then another, then another. It took many of us weeks to get the smoke in our lungs out. The wildlife is not able to leave that air. Against that lived reality, the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask the agency to explain, in plain terms, why this proposal departs from that prior finding and to reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The black bears, the moose, the otters, and the fawns we all admire along the banks of the Gallatin are the reason the following entries in the agency's own record cannot simply be papered over. The DEIS notes that moose are drawn to road corridors for road salt, which increases human-moose interactions and conflict, and separately credits the rule's protections with the recovery of moose populations where old-growth winter shelter was preserved. On bears, the DEIS quotes the federal grizzly recovery plan: increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation, and food reward all increase with the use of even secondary unpaved roads. The Gallatin Range fight has been one of the most contentious roadless battles in the country, pitting backcountry hunters and wildlife advocates against timber interests in grizzly bear habitat, and the Custer Gallatin's verified species include grizzly bear, elk, wolverine, and bighorn sheep. The agency must explain how rescission avoids those documented mortality pathways for species whose recovery depends on the very roadless conditions this rule guarantees. The sediment question deserves a direct answer that the record does not currently provide. The DEIS states that "skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and 'can contribute up to 90 percent of the sediment generated by timber sale activity.'" That number appears and then disappears. No projection of sediment delivery to downstream water follows it. I work on a river. I understand that what enters the watershed above me arrives below me. The agency should quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas before any rescission moves forward. Finally, the state-by-state replacement argument has been tried before and rejected. The record contains the agency's own prior statement of "dissatisfaction with the Roadless Rule" and its rejection of the rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. The Ninth Circuit found the prior attempt to substitute local discretion for the national rule legally deficient. The agency must address how this proposal avoids those same deficiencies and confront its own prior finding that incremental local decision-making erodes nationally significant roadless values over time. I plead that we keep wild places wild, for future generations and for the beauty that is held within them. Once they are carved apart they may never recover. Sincerely, Hayley Domancich Bozeman, Montana